Supporting Document 2
COAG Consultation Regulation Impact Statement – Proposal
P1016
Hydrocyanic Acid in Apricot Kernels & other Foods
Raw unhulled (with skin) raw apricot kernels
Raw hulled (without skin) raw apricot kernels
Contents
TABLES AND CHARTS ............................................................................................................................... 2
EXECUTIVE SUMMARY............................................................................................................................... 3
1
INTRODUCTION ................................................................................................................................... 5
2
THE PROBLEM ..................................................................................................................................... 6
3
OBJECTIVES ........................................................................................................................................ 8
4
OPTIONS ............................................................................................................................................... 9
4.1
4.2
4.3
4.4
4.5
5
OPTION 1 – MAINTAIN THE STATUS QUO .............................................................................................. 9
OPTION 2 – MANDATORY LABELLING .................................................................................................... 9
OPTION 3 – SET A MAXIMUM LEVEL ...................................................................................................... 9
OPTION 4 – PROHIBITION ON THE SALE OF RAW UNHULLED (SKIN ON) APRICOT KERNELS ................. 9
OPTION 5 – PROHIBITION ON THE SALE OF RAW APRICOT KERNELS .................................................... 9
IMPACT ANALYSIS .............................................................................................................................. 9
5.1
AFFECTED PARTIES ............................................................................................................................... 9
5.2
OPTION 1 – MAINTAIN THE STATUS QUO ............................................................................................ 10
5.3
OPTION 2 – MANDATORY LABELLING .................................................................................................. 10
5.3.1 Applying mandatory labelling requirements .............................................................................. 10
5.4
OPTION 3 – SET A MAXIMUM LEVEL .................................................................................................... 11
5.5
OPTION 4 – PROHIBITION ON THE SALE OF RAW UNHULLED (SKIN ON) APRICOT KERNELS ............... 12
5.6
OPTION 5 – PROHIBITION ON THE SALE OF RAW APRICOT KERNELS .................................................. 13
5.7
COMPARISON OF OPTIONS .................................................................................................................. 14
6
CONSULTATION ................................................................................................................................ 15
7
CONCLUSION ..................................................................................................................................... 16
8
IMPLEMENTATION AND REVIEW ................................................................................................... 17
ATTACHMENT 1 – A SUMMARY OF REPORTED POISONING INCIDENTS FROM RAW APRICOT KERNELS IN NEW
ZEALAND AND AUSTRALIA ................................................................................................................................ 18
ATTACHMENT 2 – CONSULTATION WITH INDUSTRY ......................................................................................... 21
ATTACHMENT 3 – QUESTIONS FOR CONSUMERS ............................................................................................ 27
1
Tables and Charts
14
Table 4
Costs and benefits of option 4 – Prohibition on the sale of raw unhulled
(skin on)
apricot kernels
Costs and benefits of option 5 – Prohibition on the sale of raw apricot
kernels
New Zealand Poisons Information Centre (1 January 2003 to 1 February
2013)
Victoria Poisons Information Centre (1 May 2005 to 6 February 2014)
Table 5
NSW Poisons Information Centre (1 Jan 2004 to 5 Jan 2014)
22
Table 6
Western Australia Poisons Information Centre (23 March 2002 to 31
August 2013)
Queensland Poisons Information Centre (Jan 2003 to Feb 2013)
23
Table 1
Table 2
Table 3
Table 7
2
15
21
22
23
Executive summary
This Consultation Regulation Impact Statement (Consultation RIS) has been prepared for
Proposal P1016 – Hydrocyanic acid in Apricot Kernels and Other Foods. The Consultation
RIS examines whether measures can be put in place to manage future potential public health
and safety issues from consumption of raw apricot kernels in a way that addresses the risk
for consumers, yet is mindful of the cost to industry.
The risk assessment undertaken by Food Standards Australia New Zealand (FSANZ)
indicated that consumption of raw apricot kernels, both unhulled (with skin) and hulled
(without skin), poses an acute public health and safety risk for consumers due to the risk of
cyanide poisoning (from the release of hydrocyanic acid) which can lead to death. General
symptoms of sub-lethal doses have been reported as abdominal pain, headache, dizziness,
short-term memory loss, confusion, flushing, palpitations and general illness.
There have been confirmed reports of poisoning incidents in Australia, New Zealand and
other countries (Canada, United Kingdom and other European countries) following
consumption of raw apricot kernels. Recently, FSANZ requested data on poisoning incidents
from both Australian and New Zealand poisons information centres. Data clearly show that
there have been a number of calls to poison information centres following either accidental
(children and adults) or intentional ingestion (by adults only) of raw apricot kernels
(Attachment 1).
Several raw apricot kernel products are available in Australia. There are a range of websites
that are marketing these products. Claims exist of the health benefits, for example, for the
prevention of, or curing cancer but not all have warnings in regard to the risk of cyanide
poisoning. However, claims of cancer related health benefits associated with raw apricot
kernels are not supported by the Australian medical community or Cancer Council Australia
and there is no reasonable basis nor reliable scientific evidence or expert medical opinion to
support them. Despite action having being taken against an apricot kernel retailer by the
Australian Competition and Consumer Commission (ACCC) for misleading cancer related
health claims these claims continue to be made directly and indirectly by a variety of
individuals and businesses both in Australia and overseas.
The fact that raw apricot kernel products are used by cancer patients further raises FSANZ’s
concerns about the capacity of information alone to prevent harm. The most recent poisoning
incident occurred despite the presence of clear warning labels on the packaging and on the
website from which product was purchased.
This consultation RIS considers five options for addressing the problem:
•
Option 1: Maintain the status quo
•
Option 2: Mandatory labelling of both unhulled (skin on) and hulled (skin off) raw
apricot kernels
•
Option 3: Set a maximum level for unhulled (skin on) and hulled (skin off) raw apricot
kernels
3
•
Option 4: Prohibition on the sale of unhulled (skin on) raw apricot kernels with
exemptions for raw apricot kernel-derived foods that are safe for consumption. In
parallel, require manufacturers to provide advice for consumers on the maximum
amount of hulled (skin off) apricot kernels that could safely be consumed on their
labels.

Option 5: Prohibition on the sale of unhulled (skin on) and hulled (skin off) raw apricot
kernels with exemptions for raw apricot kernel-derived foods that are safe for
consumption.
FSANZ undertook targeted consultation with industry and food enforcement agencies in
2012 and 2013 (Attachment 2). This work has informed the development of the options
explored in this Consultation RIS as well as the analysis of the impacts of each option.
However, difficulties have been experienced in obtaining sufficient information to understand
the true scope and nature of this industry.
Prior to public consultation, FSANZ considers that overall Option 5, a regulatory approach
(prohibition on the sale of both unhulled (skin on) and hulled (skin off) raw apricot kernels in
Standard 1.4.4 with exemptions for raw apricot kernel-derived foods that are safe for
consumption) is likely to have the greatest net benefit and is therefore the preferred option.
The determination that this option is likely to have the greatest net benefit is based on
qualitative analysis due to difficulty obtaining quantitative information from industry. This
prohibition relates only to food use of apricot kernels and does not extend to a prohibition on
use of foods derived from apricot kernels which does not pose health risks (e.g. as an
ingredient in other foods).
FSANZ is seeking information from submitters on a range of questions in relation to this
Proposal. These questions are provided on page 15 and 16, in Attachment 2 (pages 27 and
28) and in Attachment 3 (page 30). Information from submissions will be used to conduct
further impact analysis and to prepare a decision RIS that will be presented to decision
makers and also made publically available. The preferred option in the decision RIS may be
changed if new evidence provides sufficient grounds to recommend another option.
4
1
Introduction
Some plant-based foods contain cyanogenic glycosides which can pose potential risk to
consumers. The toxicity of cyanogenic glycosides and their derivatives depends on release
of hydrocyanic acid (HCN) from plant tissue. This may occur either after damage to the plant
or as a result of the action of gut bacteria in animals or humans after ingestion. The
concentration of HCN in seeds varies widely; however, in raw apricot seeds (kernels) it can
reach toxic thresholds (Haque and Bradbury, 2002; Codex Committee on Contaminants in
Foods, 20081). These levels can be sufficiently high to cause death in humans and the
amounts in any particular kernel can be hard to predict or control.
Throughout this report, the term ‘raw apricot kernel’ refers to the edible nut-like object found
within the shell or stone of Prunus armeniaca either unhulled (with skin) or hulled (without
skin). Hulled, raw apricot kernels are usually pale white in colour.
There have been confirmed reports of poisoning incidents in Australia, New Zealand and
other countries (Canada, United Kingdom and other European countries) following
consumption of raw apricot kernels.
Therefore, in light of these poisoning incidents and the results from a recent survey on
cyanogenic glycosides in a range of plant-based foods,2 Food Standards Australia New
Zealand (FSANZ) prepared Proposal P1016. The Proposal was prepared to assess the
public health risks of some foods derived from plants containing cyanogenic glycosides and
to develop appropriate risk management strategies to manage these risks, including
consideration of a need for food regulatory measures in the Australia New Zealand Food
Standards Code (the Code)3.
Various apricot kernel derived foods were analysed in the survey, including amaretti biscuits,
almond finger biscuits, apricot jams, apricot nectar and were found not to pose any risks to
public health and safety. Therefore, this Consultation Regulatory Impact Statement (RIS)
focuses just on apricot kernels.
FSANZ has prepared this Consultation RIS to examine the costs and benefits of various
options for managing future potential public health or safety issues from consumption of raw
apricot kernels in Australia and New Zealand.
FSANZ has made considerable effort to engage with and understand the raw apricot kernel
industry, but the collected information was not sufficient for detailed quantitative analysis of
the proposed options. Therefore, much of the analysis that has been done is qualitative.
Although the prohibition on the sale of both unhulled (skin on) and hulled (skin off) apricot
kernels is presented as a preferred option in this Consultation RIS, this may change if
evidence is presented that another option is more appropriate to manage the acute dietary
risks from consumption of raw apricot kernels.
1
Haque MR, Bradbury JH (2002) Total cyanide determination of plants and foods using the picrate and acid
hydrolysis methods. Food Chemistry, 77(1): 107-114.
Codex Committee on Contaminants in Foods. (2008) Discussion paper on cyanogenic glycosides. CX/CF
09/3/11. Rome: FAO/WHO.
2 A survey of the levels of HCN in a variety of plant-based foods available in Australia and New Zealand was
conducted as part of the Implementation Sub-Committee for Food Regulation’s (ISFR) Coordinated Food Survey
Plan to determine whether there are any public health and safety concerns for the Australian or New Zealand
populations arising from the consumption of these foods.
3 http://www.foodstandards.gov.au/code/Pages/default.aspx
5
This document, in accordance with COAG best practice regulation requirements includes the
following sections:







a statement of the problem – explaining the need for government action
a statement of the objectives of any intervention
a statement of the possible options to address the problem
an impact analysis of the options (costs and benefits)
details of the consultation undertaken
a clear statement as to which is the preferred option and why
details of how the preferred option would be implemented, monitored and reviewed.
A summary of reported poisoning incidents in Australia and New Zealand is included in
Attachment 1 and more detailed information in relation to targeted consultation with industry
to date is included in Attachment 2.
FSANZ is seeking information from submitters on a range of questions in relation to raw
apricot kernels. Questions for importers and domestic producers are provided on page 15
and 16, in Attachment 2 (pages 27 and 28) and in Attachment 3 (page 30). In addition to this
information, we would welcome any general comments, data or information on the proposed
options. If information of sufficient quality and volume can be obtained from submissions, it
will be used to conduct a more detailed quantitative impact analysis of the proposed options
and to prepare a Decision RIS that will be presented to decision makers and also be made
publicly available.
2
The problem
The problem that this Proposal seeks to address is the potential health outcomes of
hydrocyanic acid (HCN) poisoning caused by consumption of raw apricot kernels, which, if
the levels are high enough, can include death. General symptoms of sub-lethal doses have
been reported as abdominal pain, headache, dizziness, short-term memory loss, confusion,
flushing, palpitations and general illness.
The risk assessment undertaken by FSANZ indicated that consumption of raw apricot
kernels, both unhulled (with skin) and hulled (without skin), poses an unacceptable acute risk
to public health and safety for consumers due to HCN poisoning.
In May 2011 a consumer in Queensland was hospitalised after consuming raw apricot
kernels with high levels of HCN. In addition, there have been a number of confirmed reports
of poisoning incidents in other countries following consumption of raw apricot kernels.
Recently, FSANZ requested data on poisoning incidents from both Australian and New
Zealand poisons information centres. Data clearly shows that there have been a number of
calls to poison information centres following either accidental (children and adults) or
intentional ingestion (by adults only) of raw apricot kernels (Attachment 1).
During the preparation of this Consultation RIS FSANZ was notified about a further poisoning
incident that occurred in Western Australia in July 2014. The consumer was hospitalised
after consuming unhulled raw apricot kernels with high levels of HCN. The product was
recalled from the market due to high HCN levels (i.e. >3000 mg/kg)4.
4
Although the actual value was not confirmed (it was not relevant for the purpose of testing), this is the highest
level measured in Australia and New Zealand. Any level above 3000mg/kg could lead to exceedance of the ARfD
or poisoning.
6
The product packaging did contain a warning statement and directions for use with a
recommended maximum amount/day of unhulled apricot kernels that could be safely
consumed. The website from which the product was purchased also has a warning
statement with a recommended maximum amount/day of unhulled apricot kernels that could
be safely consumed.
Several apricot kernel products are available in Australia. There are a range of websites that
are marketing these products with claims of health benefits, for example, for the prevention
of, or curing cancer but not all have warnings in regard to the risk of cyanide poisoning.
However, these claims have not been proven and there is no reasonable basis nor reliable
scientific evidence or expert medical opinion to support them5.
In 2009, the Australian Competition and Consumer Commission (ACCC) took action against
a business/individual in regard to misleading claims. The business suggested that a
treatment program they were promoting was effective in the treatment of cancer by ingesting
high levels of Laetrile (also known as Amygdalin) sourced in such foodstuffs as raw apricot
kernels. However, an expert oncologist engaged by the ACCC, whose evidence was
accepted by the court, indicated that high levels of Laetrile can result in cyanide toxicity. The
Federal Court, Brisbane ruled that the business/individual engaged in misleading or
deceptive conduct in relation to certain cancer prevention and treatment claims. The ACCC
chairman stated that the ACCC acted in the public interest to protect vulnerable people who
are fighting serious or terminal illnesses. However, despite this ruling and attempts by the
NSW Food Authority and the Department of Health and other regulators to stop these
misleading claims, these claims continue to be made directly and indirectly by a variety of
individuals and businesses in Australia, New Zealand and overseas6. There appears to be
clear difficulties in preventing these claims being made.
The fact that these products are being used by cancer patients further raises FSANZ’s
concerns about the capacity of information alone to prevent harm.
There are identified acute dietary risks (exceedance of the acute reference dose (ARfD)) and
potentially severe acute poisoning associated with the consumption of raw apricot kernels.
This is supported by multiple published cases of adult and child cyanide poisoning resulting
from eating raw apricot kernels and a narrow margin of safety following consumption before
an exceedance of the ARfD or poisoning might occur7.
Raw apricot kernels consumed by the hospitalised consumer in Queensland were reported
as having levels of HCN of 2300mg/kg. This is consistent with previous reports of raw apricot
kernels having an average HCN levels of 1450 mg/kg, although internationally there have
been reports of up to 4090 mg/kg of HCN. The fact that we import a significant percentage of
raw apricot kernels from overseas and the limited size of sampling to date would suggest that
these higher levels are definitely possible in the Australian food supply. In the most recent
case, raw apricot kernels consumed by the hospitalised consumer in WA were reported as
having levels of HCN above 3000 mg/kg, which is the level where consumption of just one
kernel is likely to lead to exceedance of the ARfD, particularly for children.
There is currently no standard in the Code for HCN (hydrocyanic acid) levels in raw apricot
kernels. However, the Code does either prescribe levels of HCN or have requirements for
appropriate preparation of specific foods (e.g. sweet cassava, bamboo shoots, confectionery,
stone fruit juices, marzipan, ready-to-eat- cassava chips, etc.) to ensure safe consumption.
5
http://www.cancer.org.au/news/blog/treatment/medical-myth-natural-cancer-therapies-cant-harm-you.html
Numerous direct and indirect claims were quickly located by conducting an internet search
7 The exceedance of the ARfD can be up to nine-fold if adults consume apricot kernels at the highest levels
(2,800 mg/kg) identified in the ISFR survey. Only three kernels (with skin on) could be safety consumed by adults
and even fewer (1 or less with skin on) can be consumed safety by children.
6
7
A range of measures have been adopted overseas to manage the risk of poisoning incidents.
These include:



Advice for consumers on a recommended maximum number of apricot kernels to be
consumed per day (United Kingdom and Canada).
Apricot kernels with very high HCN levels would be captured within the scope of the
European Union Food Safety Regulations, which makes it an offence to sell or possess
for sale food which is injurious to health (28 member states of the EU).
Prohibition on sale of apricot kernels as a food since they are regulated as a drug
(laetrile (amygdalin)) under import legislation (USA)8.
In Australia, the only state that regulates Laetrile (amygdalin) is Queensland, although this is
not applicable to apricot kernels or other foods containing cyanogenic glycosides9.
A clear case exists for government intervention due to the clear risk of mortality, with children
particularly vulnerable. The purpose of the following analysis is to determine whether a nonregulatory or regulatory intervention is the most appropriate option to manage future potential
public health or safety issues from consumption of raw apricot kernels.
3
Objectives
In developing or varying a food standard, FSANZ is required by its legislation to meet three
primary objectives which are set out in section 18 of the FSANZ Act. These are:



the protection of public health and safety;
the provision of adequate information relating to food to enable consumers to make;
informed choices; and
the prevention of misleading or deceptive conduct.
In developing and varying standards, FSANZ must also have regard to:

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

the need for standards to be based on risk analysis using the best available scientific
evidence;
the promotion of consistency between domestic and international food standards;
the desirability of an efficient and internationally competitive food industry;
the promotion of fair trading in food; and
any written policy guidelines formulated by the COAG Legislative and Governance
Forum on Food Regulation.
The principal objective of this proposal is to assess what measures can be put in place to
manage future potential public health or safety issues from consumption of raw apricot
kernels.
8
The USA does not have any formal limits on HCN in foods. They previously took a case-by-case approach and if
the product was marketed as food, they looked at it from the perspective of whether it contains excessive levels of
cyanide that may render the food injurious to health and enforced on that basis. However, in 1977 the USA
considered apricot kernels to be “laetrile” (also known as amygdalin) and now detain it as a new drug under
relevant import legislation Import Alert 62-01.
9 In Queensland, oral amygdalin is not permitted and special approval is required to obtain, possess and use
intravenous or intramuscular preparations. Approval is only considered for patients with an advanced malignancy
where all possible conventional treatment has been exhausted.
8
4
Options
In order to decide on the most cost-effective approach to achieving these objectives, this
proposal considers five options.
4.1 Option 1 – Maintain the status quo
Under the status quo FSANZ would rely on the current website advice which describes the
number of raw apricot kernels that can be safely consumed per day.
FSANZ has produced an advisory statement, published on the FSANZ website, which
highlights that for adults consuming more than three raw apricot kernels per day is unsafe10.
Children are advised to consume no raw apricot kernels.
4.2 Option 2 – Mandatory labelling
This regulatory option requires FSANZ to consider whether labelling could appropriately
manage the public health and safety risk associated with the consumption of raw apricot
kernels. Labels on packages of apricot kernels would have a statement relating to the risk
associated with consuming the product.
4.3 Option 3 – Set a maximum level
This regulatory option involves setting a maximum level (ML) in Standard 1.4.1 –
Contaminants and Natural Toxicants for raw unhulled and hulled apricot kernels.
4.4 Option 4 – Prohibition on the sale of raw unhulled (skin on)
apricot kernels
This regulatory option involves preparation of draft variations to include a prohibition on the
sale of raw unhulled (skin on) apricot kernels only in Standard 1.4.4 with exemptions for
kernel-derived foods that are safe for consumption. In parallel, manufactures would be
required to provide advice for consumers on the maximum amount of raw hulled (skin off)
apricot kernels that could safely be consumed on their product labels.
This option allows the continued sale of raw hulled (skin-off) apricot kernels; however, there
would be advice provided on FSANZ’s website and on labels on the recommended maximum
amount/day of hulled apricot kernels that could be safely consumed.
4.5 Option 5 – Prohibition on the sale of raw apricot kernels
This regulatory option involves preparation of draft variations to include a prohibition on the
sale of all raw, unhulled and hulled apricot kernels in Standard 1.4.4 Prohibited and
Restricted Plants with exemptions for raw apricot kernel-derived foods that are safe for
consumption.
5
Impact analysis
5.1 Affected parties
Parties that have been identified as potentially being affected by this Proposal include:
10
http://www.foodstandards.gov.au/consumer/safety/Pages/Apricot-kernels-raw.aspx
9



industry (importers, producers and retailers);
consumers of apricot kernels; and
government.
From the consultation with industry to date, FSANZ has managed to identify only one
business that imports/produces greater than 500kg of apricot kernels per year. Based on the
information collected in 2013, (from 3 respondents) approximately 20,000kg of apricot
kernels for human consumption is imported/ produced in Australia every year. The selling
(retail) price per kg is around $30 per kilogram; therefore, the current data suggests that the
total value of the apricot kernel industry in Australia is approximately $600,000. All three
businesses are both retailers and wholesalers. Together they supply between 6 and 300011
retail business. More detailed information in relation to targeted consultation with industry to
date is included in Attachment 212.
5.2 Option 1 – Maintain the status quo
FSANZ would maintain the status quo and rely on the current website advisory statement
which describes the number of raw apricot kernels that can be consumed by adults without
harm, noting that children are advised to not consume raw apricot kernels.
As noted in the Objectives section above, the principal objective of this proposal is to assess
whether measures can be put in place to manage potential public health or safety issues
from the consumption of raw apricot kernels in a way that is appropriately mindful of the cost
to industry, consumers and government, relative to risk.
The status quo will not achieve this objective because:




A significant potential harm exists from high levels of HCN, particularly for children.
This option is unlikely to allow FSANZ to adequately ensure public safety due to the
uncertainty surrounding the absolute maximum levels of HCN that could potentially be
present in unhulled or hulled apricot kernels.
Effectiveness of website advice is likely to be limited, as it is dependent on consumers
seeking and being aware of this information.
Costs to the government of future incidents and health treatments.
5.3 Option 2 – Mandatory labelling
5.3.1
Applying mandatory labelling requirements
FSANZ has considered whether labelling could appropriately manage the public health and
safety risk associated with the consumption of raw apricot kernels.
Labelling is not considered an appropriate risk management option for the following reasons:

Labelling is not appropriate to mitigate a potentially serious public health risk for the
general community where public awareness of the risk is low.

The variability in the HCN levels and in particular maximum limits of HCN means that,
similar to option 1, it is difficult to predict a safe number of kernels that could be
consumed per day.
11
The figure of 3,000 was reported to FSANZ from an importer/domestic producer of raw (skin on) apricot
kernels.
12 Survey was sent to 46 businesses in both, Australia and New Zealand. FSANZ has not received any responses
from New Zealand business.
10
This variation means that it would be impractical to determine a labelling statement that
would be adequate to address the acute public health implications for all potential
consumers. Furthermore, any advice on maximum consumption could become out-ofdate as more information on the maximum levels which may occur becomes
available13.
There are identified acute dietary risks (exceedance of the acute reference dose (ARfD)) and
potentially severe acute potential poisoning associated with the consumption of raw apricot
kernels. This is supported by multiple published cases of adult and child cyanide poisoning
resulting from eating raw apricot kernels and a narrow margin of safety following
consumption before an exceedance of the ARfD or poisoning might occur. Therefore, the
general availability of raw apricot kernels, including for children (which is the group at
greatest risk of exceeding safe doses) means that it would be inadequate to rely on specific
labelling statements to protect public health and safety.
The most recent poisoning incident occurred in WA despite the presence of clear warning
labels on the packaging and website from which product was purchased.
Average cost of a labelling change would be somewhere around $5,624 per single stock
keeping unit (SKU)14.
5.4 Option 3 – Set a maximum level
5.3.2
Set a maximum level (ML) in Standard 1.4.1 – Contaminants and Natural
Toxicants for raw unhulled unprocessed kernels and/or hulled processed
apricot kernels
An ML is usually established where it serves an effective risk management function, at a
level which is consistent with the protection of public health and safety, and which is
reasonably achievable. Therefore, FSANZ considered whether an ML option would be
appropriate for raw apricot kernels.
The Implementation Subcommittee for Food Regulation (ISFR) survey found that all apricot
kernel samples analysed contained detectable levels of HCN. However, there was a
significant difference and large variability in the range of HCN concentrations between
individual kernels with and without skin. Levels of HCN in 18 kernels with skin ranged from
1,240-2,820 mg HCN/kg; and for the ten kernels without skin a range of 49-440 mg HCN/kg
was present.
FSANZ considers that it is inappropriate to set an ML, as it would not serve as an effective
mitigation measure for HCN in raw apricot kernels, for the following reasons:

If an ML was set, it would need to be at a level significantly below the range seen in the
test samples (at least ten-fold). The numbers of kernels analysed were low (18 in total)
so they do not represent the worst case in terms of maximum levels of HCN attainable
and therefore the risk may be underestimated based on current information. Therefore,
an ML set on current data would require the use of uncertainty factors in order to be
protective of human health. It is therefore very unlikely that an ML could be set that is
achievable.
the time of the first poisoning incident in Queensland, FSANZ’s advice was to consume no more than
4 kernels / day. However, due to more recent data from the ISFR survey, that advice has now needed to be
updated to advise consumers of the reduced number of kernels that can now be safely consumed.
14 Cost Schedule for Food Labelling Changes - 2014 PricewaterhouseCoopers Report commissioned by
Department of Health
13At
11
FSANZ does not believe that it would be possible to obtain or process raw apricot
kernels to achieve an HCN level that would be compliant with an ML that would be
protective of human health and safety.

The wide variation in levels of HCN in raw apricot kernels would make any process
control arrangements (including sampling plans) complex and difficult to achieve
consistency. This variability and uncertainty increases when considering unhulled and
hulled raw kernels.

The FSANZ Risk Assessment was completed prior to the latest poisoning incident in
WA. The results of testing in that incident suggest that the levels of HCN in apricot
kernels can be higher than those found in the ISFR Survey report.
5.5 Option 4 – Prohibition on the sale of raw unhulled (skin on)
apricot kernels
Prepare draft variations to include a prohibition on the sale of raw unhulled (skin on) apricot
kernels only in Standard 1.4.4 with exemptions for raw kernel-derived foods that are safe for
consumption. In parallel, advice on FSANZ’s website and on food labels for consumers on
the maximum amount of raw hulled (skin off) kernels that could safely be consumed.
This option allows the continued sale of raw hulled (skin-off) apricot kernels only; however,
there would be advice provided on FSANZ’s website on the amount/day of hulled apricot
kernels that could be safely consumed per day. Additionally mandatory labelling of raw
hulled (skin off) kernels would be required to advise consumers of the health risks of
exceeding recommended consumption levels. The costs and benefits relating to labelling are
discussed under Option 2 above. The costs and benefits of prohibiting the sale of unhulled
apricot kernels are compared below:
Table 1: Costs and benefits of option 4 – Prohibition on the sale of raw unhulled (skin
on) apricot kernels
Affected party
Government
Costs
Benefits
Impacts
Associated costs to enforce the prohibition of raw unhulled apricot
kernels.
Gives certainty in enforcing the state and territory food acts (under
the safe and suitable legislation).
Partially reduces likelihood and subsequent health costs of further
poisoning incidents caused by consumption of raw unhulled apricot
kernels.
Industry
Costs
Benefits
Immediate costs to profits and reduced revenue for industry on
account of the removal of all raw unhulled apricot kernels, which are
not intended to be further processed before sale, from the market.
Revenue loss might be reduced if consumers switch purchases to
raw hulled kernels.
Reduce the risk of food poisoning events from raw unhulled apricot
kernels and associated costs of such events.
12
Affected party
Consumers
Costs
Benefits
Impacts
Denies access to raw unhulled apricot kernels for those consumers
who seek to buy raw unhulled apricot kernels. However, it should be
noted that much of this demand may be a result of unreliable
information.
For consumers, a reduction in risk of dietary exposure to HCN from
raw unhulled apricot kernels.
Avoids consumers inappropriately relying on apricot kernels to avoid
or cure cancer.
This option was considered because there is a difference in the maximum concentration of
HCN between skin on and off varieties. For the skin on kernels, a maximum level of HCN of
2,820 mg/kg from the ISFR survey was used in the risk assessment. Calculations showed
that adults could consume only three kernels per day before the safe level is exceeded and
that children would be at risk from consumption of only one kernel per day. Whereas, for the
raw hulled, skin off kernels, the maximum level of HCN was 440 mg/kg and adults could
consume 21 kernels per day and children could consume 6 kernels per day before the safe
level is exceeded. However, due to the variability in HCN levels in both varieties, there is still
considerable uncertainty in estimating maximum numbers that could be safely consumed
(particularly for children) as there have been reports of up to 4,090 mg/kg for skin on
varieties in the international scientific literature. As noted above higher levels were found in
the recent (July 2014) incident, indicating it is also likely that higher levels will be found in
hulled (skin off) varieties than was determined in the survey meaning even a small number
could cause adverse health effects.
1.
How many additional steps are involved in removing skin from raw unhulled
(skin on) apricot kernels?
2.
How much would it cost to set up additional production processes for removing
the skin from raw unhulled (skin on) apricot kernels?
5.6 Option 5 – Prohibition on the sale of raw apricot kernels
5.6.1
Prepare draft variations to include a prohibition on the sale of raw apricot
kernels in Standard 1.4.4 with exemptions for apricot kernel-derived foods that
are safe for consumption.
Prohibition on all raw, unhulled and hulled apricot kernels in Standard 1.4.4 – Prohibited and
Restricted Plants and Fungi with an exemption for raw apricot-kernel derived oils and foods
that do not have safety concerns. The costs and benefits are compared below:
Table 2: Costs and benefits of option 5 – Prohibition on the sale of raw apricot kernels
Affected party
Government
Costs
Benefits
Impacts
Associated costs to enforce the prohibition.
Gives certainty in enforcing the state and territory food acts (under
the safe and suitable legislation).
Reduces likelihood and subsequent health costs of further poisoning
incidents.
13
Affected party
Industry
Costs
Benefits
Consumers
Costs
Benefits
Impacts
Loss of revenue and profits from the prohibition for sale of all raw
unhulled and hulled apricot kernels, which are not intended to be
further processed before sale from the market.
Reduce the risk of food poisoning events and associated costs of
such events.
Denies access to raw unhulled and hulled apricot kernels for those
consumers who seek to buy them. However, it should be noted that
much of this demand may be a result of unreliable information.
For consumers, a reduction in risk of dietary exposure to HCN from
raw unhulled and hulled apricot kernels and the associated negative
health consequences.
Avoids consumers inappropriately relying on apricot kernels to avoid
or cure cancer.
Some consumers may feel aggrieved about losing access to the product but this sense of
loss is based on unreliable information that consumption of raw apricot kernels assists in the
avoidance and cure of cancer and as a ‘natural cancer therapy’ there are no harmful effects.
Laetrile, an extract from apricot kernels, was for years promoted as a natural alternative
therapy for cancer; yet its efficacy for cancer is unproven with clinical trials in humans failing
to find any benefits. Taking Laetrile, or eating apricot kernels in large amounts, is not only
ineffective at treating cancer but could also cause fatal cyanide poisoning15.The successes
claimed by its supporters are based on individual reports, testimonials, and publicity issued
by promoters. Concerns exist about individuals relying on this type of treatment alone, and
avoiding or delaying conventional medical care for cancer. This could have serious health
consequences16.
The intent of option 5 is not to prohibit the use of apricot kernels for safe uses as an
ingredient in other foods (e.g. confectionery). FSANZ does not regulate the use of kernels in
cosmetic products, which are unaffected by this proposal. It is acknowledged that whole
kernels may be purchased for home-cooking or possibly catering use, although we believe
this market is very limited. Therefore loss of availability of this ingredient is likely to be of
minor impact.
Questions for importers and producers are provided on page 15 and in Attachment 2,
pages 27 and 28. If you have previously supplied any of this information to FSANZ,
there is no need to provide it again.
Questions for consumers are provided on page 30, Attachment 3.
5.7 Comparison of options
FSANZ concludes that due to the serious nature of the acute risk to human health, option 5
(prohibition on the sale of apricot kernels) is the preferred option to address the public health
and safety risks posed by consumption of raw unhulled and hulled apricot kernels.
15
16
http://www.iheard.com.au/question/eating-apricot-kernels-cure/
American Cancer Society - http://www.cancer.org/
14
Whilst it is recognised that there will be costs to industry arising from a strict regulatory
option, consumers will benefit by lowering or elimination of the potential serious adverse
effects and misleading claims of improved health benefits from consumption of raw apricot
kernels (that has never been proven or supported by adequate scientific evidence).
FSANZ considers that maintaining the status quo (a non-regulatory approach) or other
regulatory options are not appropriate options for the following reasons:

A significant potential harm exists from high dietary levels of HCN particularly for
children.
Options 1, 2, 3 and 4 are unlikely to adequately ensure public safety due to the
uncertainty surrounding the absolute maximum levels of HCN that could potentially be
present in raw unhulled or hulled apricot kernels.
Effectiveness of website advice and labelling is likely to be limited, as it is dependent
on consumers seeking and noticing and taking account of this information.
Option 3 – even if an ML was set, it would be at such a low level that, in effect, it would
lead to a similar outcome as the proposed prohibition in Option 5.



Based on the experience from previous poisonings and the latest poisoning incident in WA
we can conclude that options 1, 2, 3 and 4 would not adequately protect public health and
safety.
The determination that this option is likely to have the greatest net benefit is based on
qualitative analysis. Further development of this option and additional information from the
consultation may enable FSANZ to conduct a more quantitative analysis for the Decision
RIS, depending on the quality of data/information received from affected parties. This could
potentially result in FSANZ arriving at a different preferred option.
6
Consultation
FSANZ has made considerable efforts to engage with and understand the raw apricot kernel
industry.
Through targeted consultation FSANZ has been seeking data and/or information on the
nature, size and costs of production of the apricot industry.
In April 2012, a targeted consultation seeking data and/or information on the nature of the
industry, size and costs of production or importation for raw apricot kernels was undertaken
with four apricot kernel business identified by an online search. Identified businesses were
approached via email. FSANZ received two responses (see Attachment 2).
In September 2013, a letter was sent out to 46 businesses in Australia and New Zealand
(importers, producers and retailers) to invite participation in FSANZ’s considerations of this
Proposal. FSANZ received five responses (see Attachment 2).
In November 2013, a more detailed questionnaire was sent out to 46 businesses (importers,
producers and retailers). FSANZ received eight responses; all from Australia (see
Attachment 3). Two businesses indicated that they no longer import apricot kernels. Another
two businesses import either apricot kernel oil17 or apricot kernels as part of ingredients used
in soup mixes. One importer indicated that they would provide some information, but to date
no response has been received. Three other businesses provided their import/production
numbers, costs and other information.
17
They have a requirement from their suppliers that Apricot kernel oil is Hydrocyanic acid free.
15
From the consultation with industry to date, FSANZ has managed to identify only one
business that imports/produces greater than 500kg of apricot kernels per year. Based on the
information collected in 2013, (from 3 respondents) approximately 20,000kg of apricot
kernels for human consumption are imported/ produced in Australia every year. The selling
(retail) price per kg is around $30 per kilogram; therefore, the current data suggests that the
total value of the apricot kernel industry in Australia is approximately $600,00018. All three
businesses are both retailers and wholesalers. Together they supply between 6 and 3000
retail business. More detailed information in relation to targeted consultation with industry to
date is included in Attachment 2. This work has informed the development of the options
explored in this Consultation RIS, but collected information was not sufficient for the detailed
quantitative analysis of the proposed options. In this report most of the analysis is done
qualitatively.
FSANZ is seeking further information and feedback from industry, consumers and other
stakeholders through this document.
All public comments received are reviewed and considered before approval of a variation to
the Code by the FSANZ Board.
Individuals and organisations making submissions on this Proposal will be notified at each
stage of assessment.
Work plan and timelines for this proposal are available on FSANZ website at
http://www.foodstandards.gov.au/code/changes/workplan/Pages/default.aspx
7
Conclusion
Having reviewed the five options described above, FSANZ concludes that, due to the serious
nature of the acute dietary exposure risk, a regulatory approach (namely a total prohibition) is
the preferred option to address the public health and safety risks posed by consumption of
raw unhulled and hulled apricot kernels for the following reasons:

it lowers the risk of future poisoning incidences from consumption of raw apricot
kernels that may contain high levels of HCN

it protects new consumers unaware of risks of consumption of raw apricot kernels and
enhances community confidence that regulatory authorities are acting to ensure public
health and safety of the food supply

it provides certainty in enforcing the state and territory and New Zealand food acts
(under the safe and suitable legislation)

it does not impose a burden on governments of ongoing surveillance of levels of HCN
in raw apricot kernels.
FSANZ considers that maintaining the status quo (a non-regulatory approach) or other
regulatory options are not appropriate options.
Option 5 (prohibition on the sale of apricot kernels) would also apply to any food derived from
raw apricot kernels with an exemption for the following:
18
Survey was sent to 46 businesses in both, Australia and New Zealand. FSANZ has not received any responses
from New Zealand business.
16









apricots containing raw apricot kernels
alcoholic beverages
oil
flavourings
stone fruit juices
marzipan
cakes
biscuits
confectionery
Non-food uses are not affected by this proposal. In practice the prohibition would mainly
affect consumers of whole kernels. Based on the information we have available to date we
predict there would be a very limited or insignificant impact due to the removal from retail
sale of kernels for catering and home-cooking.
As this is a Consultation RIS we welcome additional comments, information and data that
you believe we should take into account in developing the Decision RIS. If information of
sufficient quality and volume can be obtained from submissions, it will be used to conduct a
more detailed quantitative impact analysis of the proposed options for the decision RIS. This
could potentially result in FSANZ arriving at a different preferred option.
8
Implementation and review
Details on the implementation and transition times for any regulatory changes will be
determined at a later stage of this process. Decisions regarding implementation and
transition will be informed by submitters’ comments received in response to this Consultation
RIS.
State and territory regulatory agencies and the Department of Agriculture would be
responsible for implementing any standard in Australia. The Ministry for Primary Industries
would be responsible for implementing the standard in New Zealand.
17
Attachment 1 – A summary of reported poisoning incidents from
raw apricot kernels in New Zealand and Australia
It has been suggested that acute HCN poisoning is qualitatively similar between children and
adults, but children may be more vulnerable than adults to poisoning from some sources19.
FSANZ found two publications describing lethal consequences from consumption of apricot
kernels:

Sayre and Kaymakcalavu (1964) report that between 1957 and 1962, two children died
of cyanide poisoning in a hospital in Central Turkey after eating apricot kernels. No
information was provided on how many kernels were consumed20.

Lasch and Shawa (1981) report two more deaths of children in Gaza. One had been
part of a group that had been “feasting on apricot kernels,” according to their parents,
and another had consumed a sweet prepared from apricot kernels. Once again, there
was no information on how much was consumed21.
Recently, FSANZ requested data on poisoning incidents from both Australian and New
Zealand poisons information centres. Data clearly show that there have been a number of
calls to poison information centres following either accidental (children and adults) or
intentional ingestion (by adults only) of raw apricot kernels.
Table 3: New Zealand Poisons Information Centre (1 January 2003 to 1 February 2013)
Circumstances
Total number of
calls/reports on
poisons centres’
databases
Adult intentional
4
Adult unintentional
9
Child unintentional
(accidental or
exploratory)
7
Total
Further information
Adults ingested a large number of apricot kernels as an
alternative medicine and developed symptoms of
cyanide toxicity: abdominal pain, headache, dizziness,
short-term memory loss, confusion, flushing, palpitations
and general illness. The then New Zealand Food Safety
Authority managed these incidents by providing general
advice on consumption of apricot kernels.
Accidentally ingested as part of a kernel or a whole
kernel intact.
20
19
http://www.ncbi.nlm.nih.gov/pubmed/17079589
Sayre and Kaymakcalavu (1964)
21 Lasch and Shawa (1981)
20
18
Table 4: Victoria Poisons Information Centre (1 May 2005 to 6 February 2014)
Circumstances
Total number of
calls/reports on
poisons centres’
databases
Adult intentional
15
Adult for reasons
other than cancer
treatment
12
Child unintentional
(accidental or
exploratory)
6
Total
Further information
Taken as a cancer treatment. Three cases of
poisoning reported with symptoms of cyanide toxicity
reported as ‘grey-looking’, lightheaded, loss of
consciousness, nausea and vomiting.
One caller said he was taking the kernels for ‘health
benefits’; another said she was taking them ‘as a
tonic’; the others did not specify why they were taking
them.
33
Table 5: NSW Poisons Information Centre (1 Jan 2004 to 5 Jan 2014)
Circumstances
Total number of
calls/reports on
poisons centres’
databases
Adult intentional
11
Adult unintentional or
other than cancer
treatment or unknown
26
General queries
27
Child unintentional
(accidental or
exploratory)
13
Total
77
Further information
As a cancer treatment. Reported as ingesting
between 20-50 kernels in a few hours or a number of
kernels daily over a period of weeks or years to treat
cancer. General symptoms of cyanide toxicity:
swelling of face, increased heart rate, vomiting,
difficulty breathing, and dizziness. Some callers
advised to attend hospital immediately, particularly
those that had ingested 30 or more kernels.
To improve general health, accidental (e.g. mistaken
for almonds or using kernels in a home-made jam
recipe) or reasons unknown. Reported as ingesting
some, few, handful or specific amounts (2-30) of
apricot kernels.
General queries for advice and concerns about or
following consumption of apricot kernels (including
recalls) to NSW poison information centre.
Children (accidental) were asymptomatic but
reported as sucked on a kernel, ingested a bit of a
kernel or 1 whole kernel consumed.
19
Table 6: Western Australia Poisons Information Centre (23 March 2002 to 31 August 2013)
Circumstances
Total number of
calls/reports on
poisons centres’
databases
Adult intentional
7
Adult unintentional
11
Adult unknown
2
Further information
Used as a complementary medicine, or suicide or
other reasons. Reported as ingesting 20-40 kernels
and lead to neurological, cardiovascular or
gastrointestinal symptoms.
Accidental food poisoning. Reported as ingesting
between 1 to 20 apricot kernels.
Child intentional
2
2 children were fed ground up apricot kernels by the
mother over several months. There was a concern as
both children were losing weight. Strongly
recommend for a medical review.
Child unintentional
(accidental or
exploratory)
4
Generally reported as ingesting 1 whole kernel
Total
26
Table 7: Queensland Poisons Information Centre (Jan 2003 to Feb 2013)
Circumstances
Total number of
calls/reports on
poisons centres’
databases
Further information
Ingestion of apricot kernels as an alternative
medicine (8) and deliberate self-poisoning (1)
Amounts consumed varied from a single apricot
kernel swallowed whole to 20 kernels a day for 4
weeks
Adult intentional
9
Symptoms reported: stomach upset and cramps,
flushed, breathing problems, swollen face,
headache, light headedness, confusion, numbness
in feet.
No patient outcomes are available.
Adult unintentional
(accidental)
Child unintentional
(accidental or
exploratory)
Total
4
1
14
The number of patients (includes all patient
types) that were symptomatic= 11
20
Attachment 2 – Consultation with industry
Consultation in April 2012
In April 2012, a targeted consultation was undertaken with four apricot kernel business
(importers and retailers) identified by online search. Identified business where approached
via email.
At that time, FSANZ asked two specific questions:
1.
2.
Do you import or produce apricot kernels in Australia or New Zealand?
What is the size of your production and/or imports and the associated costs of
production of apricot kernels?
Responses were received from two businesses that both produce Australian grown apricot
kernels. One business indicated that their apricot kernels are not being used as food and
another business produces around 7 tons of apricot kernels that are used as food.
One of the producers mentioned that they are also looking to import approx. 4 - 6 tonnes for
certified organic apricot kernels to supply the Australian market. Organic apricot kernels are
non-existent in commercial quantities in Australia so they stated that they need to look
abroad to meet the demand in Australia for this popular food.
Letter to industry in September 2013
In September 2013, a letter was sent out to 46 businesses (importers, producers and
retailers) in both Australia and New Zealand. Approached businesses were identified by
online research and from customs import data. FSANZ received five responses.
The purpose of this letter from FSANZ was to inform the apricot kernel industry about
Proposal 1016 and invite them to subscribe to FSANZ standards management mailing list for
P1016, and let them know that we will be calling for data and/or information to assist FSANZ
in estimating impacts on industry.
Please see below a copy of the letter sent to apricot kernel business in September 2013.
21
Dear Sir/Madam
Food Standards Australia New Zealand (FSANZ) is a bi-national scientific government agency
responsible for setting food standards in Australia and New Zealand.
FSANZ is currently progressing a Proposal (P1016) to identify potential public health and safety risks
associated with the consumption of raw apricot kernels and food products derived from them. For
more background information refer to the following links:
http://www.foodstandards.gov.au/foodstandards/changingthecode/standardsworkplan.cfm and
http://www.foodstandards.gov.au/code/proposals/Pages/proposalp1016hydrocy5438.aspx
As part of our assessment, FSANZ will consider appropriate risk management strategies to manage
any identified public health and safety risks. We are obliged to consider the potential benefits and
costs that may result from any proposed food regulatory measures (non-regulatory or regulatory).
There are a number of options that could achieve the desired outcome of protection of public health
and safety and FSANZ will need to examine the regulatory impacts of each option.
These consist of:




a non-regulatory approach (e.g. consumer education) that may incorporate advice on the
recommended maximum number of apricot kernels/day)
complete prohibition on the sale of raw apricot kernels with an exemption for safe food products
derived from them
setting a maximum limit (ML) for HCN in raw apricot kernels and if needed, for food products
derived from them
labelling (with advice on the maximum number of raw apricot kernels that could be consumed in
a day without adverse health effects)
FSANZ expects to have completed its risk assessment and options for consideration by the FSANZ
Board in December this year. We will be calling for data and/or information that can assist in
estimating impacts on industry. While any data provided will be used to arrive at a general profile of
the apricot kernel industry across Australia and New Zealand, you will not be identified as the source
of information.
The information you provide will be treated in confidence and will not be published by FSANZ.
However, the information may be subject to a freedom of information request once it is in FSANZ’s
possession. Exemptions to the release of data do exist. However, exemptions are qualified and
businesses do not get a right of veto over disclosure.
Therefore, in order that you can assist FSANZ at the time of public consultation on this Proposal, we
invite you to supply your details on our submitter’s data base, as follows:
Keeping informed
You can be placed on a mailing list for future advice on a specific application or proposal by contacting
the Standards Management Officer at standards.management@foodstandards.gov.au and attaching
this completed form (word 101 kb).
You can also register online to read about applications and proposals FSANZ is developing by
registering to our subscription service. For assistance in registering online contact the FSANZ
Information Officer in Australia email information@foodstandards.gov.au
If you have any specific clarifications or require further information, please contact the Project
Manager, Dr Glenn Stanley or (02) 62712643 or glenn.stanley@foodstandards.gov.au.
22
Consultation in November 2013
In November 2013, a questionnaire was sent out to 46 businesses (importers, producers and
retailers) in both Australia and New Zealand. Businesses were identified by online research
and from customs import data. Please see a copy of the questionnaire sent to apricot kernel
businesses below.
FSANZ received eight responses, all from Australia. Two businesses indicated that they no
longer imported apricot kernels. Another two businesses import either apricot kernel oil17or
apricot kernels as part of ingredients used in soup mixes. One importer indicated that they
would provide some information, but to date no response has been received. Three other
businesses provided their import/production numbers, costs and other information.
Responses were received from three businesses, two of which only import apricot kernels,
and one business that imports and domestically produces apricot kernels. One of those
businesses imports only apricot kernels without skin (hulled) and the other two only apricot
kernels with skin on (unhulled). They import between 450–7,000 kg of apricot kernels with
skin on (unhulled) for about $5–7 per kg and around 500kg of apricot kernels with skin off
(hulled). Also, a third business produces around 9,000–12,000 kg of dried apricot kernels
with skin on (unhulled) for around $9.5/kg.
All three businesses do retail and wholesale. Together they supply between 6 and 3000 retail
business.
23
Questions sent to targeted stakeholders in 2013
Further information in response to these questions is requested. If
you have previously supplied any of this information to FSANZ
there is no need to supply it further.
a) Questions for apricot kernel importers
If your business is based in Australia we will assume your answers to the following
questions are in Australian dollars. If it is based in New Zealand we will assume
answers are in New Zealand dollars. If it is in both countries please provide
answers in Australian dollars.
In which country is your business based? Write Y in the box next to the country(ies) in which
your business is based.
Australia
New Zealand
How many kilograms of apricot kernel products do you import per year?
What type of apricot kernel products do you import? (e.g. dried apricot kernels, apricot kernel
oil). And how many kilograms of apricot kernel product do you import?
Apricot kernel product
Quantity imported per year (in
kilograms)
Price your
business pays for
imports $
Dried apricot kernels with skin on
(unhulled)
Dried apricot kernels without skin
(hulled)
Apricot kernel oil
Other foods22 (please specify)
What percentage of your imported dried apricot kernels goes in to further processing for foods
derived from apricot kernels23? This includes both processing your business undertakes and
processing by other businesses you sell to.
Does your business also sell apricot kernel products directly to consumers?
22
23
For example (amaretti biscuits, almond finger biscuits, apricot jams, apricot nectar)
For example (apricot kernel oil, amaretti biscuits, almond finger biscuits, apricot jams, apricot nectar)
24
How many retail businesses do you supply apricot kernel products to?
b)
Questions for domestic apricot kernel producers
If your business is based in Australia we will assume your answers to the following
questions are in Australian dollars. If it is based in New Zealand we will assume
answers are in New Zealand dollars. If it is in both countries please provide answers
in Australian dollars.
In which country is your business based? Write Y in the box next to the country(ies) in which
your business is based.
Australia
New Zealand
What type of apricot kernel products do you produce? (eg. dried apricot kernels, apricot kernel
oils) And how many kilograms of each type of apricot kernel products do you produce?
Apricot kernel product
Quantity produced per year (in
kilograms)
Dried apricot kernels with
skin on (unhulled)
Dried apricot kernels
without skin (hulled)
Apricot kernel oil
Other foods24 (please
specify)
What are the costs your business incurs in producing apricot kernels with skin on (unhulled)
and apricot kernels without skin (hulled)? (e.g. – agricultural costs, harvesting costs, storage
costs, processing costs, packaging, labelling, etc.)
Apricot kernel product
Production costs $
Apricot kernels with skin on (unhulled)
Apricot kernels without skin (hulled)
Does your business sell apricot kernel products directly to consumers?
24
For example, (amaretti biscuits, almond finger biscuits, apricot jams, apricot nectar)
25
How many retail businesses do you supply apricot kernel products to?
26
Attachment 3 – Questions for consumers
Apricot kernels are nut-like seeds found in the stone of fresh apricots. They can be bought
with the skin on (unhulled) or with the skin off (hulled). Some processed foods, such as
amaretti biscuits and apricot jam can include apricot kernels as an ingredient.
1 Skin on (unhulled) apricot kernels
2 Skin off (hulled) apricot kernels
Question 1. Have you ever bought dried apricot kernels…? Please tick all that apply.
A
On their own (e.g. a bag of dried apricot kernels)
B
As part of a soup mix?
C
In a food in which they’re used as an ingredient (e.g. biscuits, apricot jam)?
D
As apricot kernel oil?
E
In some other form. Please specify
If you did not tick ‘On their own’ (Box A above) please do not complete any further questions in
this survey. At this stage, FSANZ is interested only in consumers purchasing or consuming
apricot kernels on their own. Thank you for your time.
If you did tick ‘On their own’ please go to Question 2.
Question 2. When you have bought apricot kernels on their own (e.g. a bag of dried apricot
kernels), which of the following types have you bought? Please tick all that apply.
Kernels with skin on (unhulled)
Kernels with skin off (hulled)
Question 3. If apricot kernels with skin on (unhulled) are unavailable would you switch to
buying apricot kernels without skin (hulled) if they were available?
Yes
No
27
Question 4. Thinking about all of the times you have bought apricot kernels, which of the
following have you used them for? Please tick all that apply
A
To prepare a particular food (e.g. biscuits, apricot jam) in which the kernels are
cooked?
B
To prepare something other than food (e.g. a body scrub)
C
To eat for health reasons
If you did not tick ‘To eat for health reasons’ (Box C above) please do not complete any further
questions in this survey. At this stage, FSANZ is interested only in consumers purchasing or
consuming apricot kernels to eat for health reasons. Thank you for your time.
If you answered ‘To eat for health reasons’ (Box C above), please answer Question 4, below.
Question 5. When you eat apricot kernels, how do you usually prepare them?
A
I usually eat them raw (uncooked) and whole
B
I usually eat them raw (uncooked) and crushed
C
I usually cook them
Question 6. Which of the following health effects (if any) are you hoping to achieve by
consuming apricot kernels?
A
I’m not trying to achieve any health benefits from consuming apricot kernels
B
I don’t currently have cancer, but I am trying to reduce my risk of developing it (i.e.
cancer prevention)
C
I currently have cancer, and am trying to treat the cancer
D
I am trying to strengthen my immune system
E
I am trying to manage arthritis pain
F
I am trying to lower my blood pressure
G
I am hoping to achieve some other health effect. Please specify
28
Apricot kernels contain hydrocyanic acid, and so can cause cyanide poisoning when
consumed. Processing apricot kernels (for example by cooking them) reduces the cyanide to
safe levels. So products, such as biscuits, jams, etc. do not pose a risk to consumers.
Please see the Food Standards Australia New Zealand website if you would like further
information on the risks of consuming raw apricot kernels:
http://www.foodstandards.gov.au/consumer/safety/Pages/Apricot-kernels-raw.aspx
Question 7. Were you aware, before reading this survey, that eating raw apricot kernels can
cause cyanide poisoning?
Yes
No
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